BioTelemetry, Inc.
Conflict Minerals Report for the year ended December 31, 2018
This Conflict Minerals Report of BioTelemetry, Inc. for the year ended December 31, 2018, is provided pursuant to Rule 13p-1 under the Securities Exchange Act of 1934, as amended (the “Rule”). The Rule was adopted by the U.S. Securities and Exchange Commission (the “SEC”) to implement disclosure and reporting requirements pursuant to Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. As permitted by the Rule and in accordance with guidance issued by the SEC on April 29, 2014, this report has not been subject to an independent private sector audit.
1. Introduction
BioTelemetry, Inc. (hereinafter “BioTelemetry,” the “Company,” “we,” “us,” or “our”) provides remote cardiac monitoring, remote blood glucose monitoring, centralized core lab services for clinical trials and original equipment manufacturing that serves both healthcare and clinical research customers. BioTelemetry operates under two reportable segments: Healthcare and Research. The Healthcare segment is focused on the diagnosis and monitoring of cardiac arrhythmias or heart rhythm disorders. The Research segment is engaged in central core laboratory services providing cardiac monitoring, imaging services, scientific consulting and data management services for drug and medical device trials.
On July 12, 2017, BioTelemetry completed the acquisition of LifeWatch AG, and in accordance with the Rule, the business acquired will be part of our 2019 reporting and compliance included on the Form SD to be filed in 2020.
This report has been prepared by the management of BioTelemetry.
In accordance with the Rule, this report is available on our website: www.gobio.com/investors/corporate-governance/.
2. Supply chain description and Reasonable Country of Origin Inquiry
2.1 General information on BioTelemetry’s supply chain
The hardware provided by BioTelemetry largely consists of electronics. Our supply chain is complex with multiple tiers of suppliers, and we are a remote downstream participant. For manufacturing, BioTelemetry purchases customized and standardized components from several global providers as well as from local and regional suppliers, either off-the-shelf or in accordance with BioTelemetry’s design or specifications. Certain types of components are produced in-house. The production of printed circuit boards and molded plastic components is mostly outsourced to manufacturing services companies. Final configuration of products is largely done in-house and on-demand. This consists of assembling and testing modules and integrating them into complete units.
2.2 Overview of BioTelemetry’s Conflict Minerals Program and Reasonable Country of Origin Inquiry
BioTelemetry gathers conflict minerals information from our suppliers. Through this we know that many of our products contain tin, tantalum, tungsten and gold (“3TG”) that are necessary to the functionality of those products.
As part of BioTelemetry’s commitment to responsible sourcing, human rights and sustainability, it is our goal that the 3TG in our products should not, directly or indirectly, finance or benefit armed groups in the Democratic Republic of Congo or adjoining countries (collectively, the “DRC”). At the same time, we aim to continue supporting responsible mineral sourcing in the region. BioTelemetry’s efforts with respect to 3TG are aligned to the work of the Conflict-Free Sourcing Initiative (“CFSI”) and our aim is to improve the traceability in our supply chain.
BioTelemetry does not ban materials from the DRC or avoid using 3TGs. We have a program team and utilize outside advisors to fulfill compliance with the Rule, perform the Reasonable Country of Origin Inquiry and report on 3TG. This team is responsible for BioTelemetry’s 3TG implementation work and senior management is regularly informed about matters relating to 3TG.
BioTelemetry relies on its first-tier suppliers to provide information on the origin of 3TG contained in components and parts included in BioTelemetry’s products. This includes sources of 3TG that are supplied to them from sub-suppliers. Our first-tier suppliers are similarly reliant upon information provided by their upstream suppliers. Certain of BioTelemetry’s large hardware suppliers are also SEC registrants and subject to the Rule.
The identification of first-tier suppliers of BioTelemetry that are in scope under the Rule involves different regions, business units and production sites that are part of BioTelemetry’s global organization. The sourcing organization has an important role in leading and coordinating the work. Suppliers identified to be in scope are first-tier suppliers of BioTelemetry supplying (i) products containing 3TG that BioTelemetry contracts to manufacture, (ii) materials, parts, components and other products, containing 3TG, that are incorporated into or included in a product manufactured by BioTelemetry, or (iii) materials used in the production of BioTelemetry’s products where 3TG becomes part of the final product. Suppliers of products that BioTelemetry does not contract to manufacture (i.e. products purchased “off the shelf”) and not included in, or incorporated into, a BioTelemetry product have been considered out of scope for purposes of the Rule. In our annual inquiry, we survey first-tier suppliers identified to be in scope and analyze and follow up upon responses as we deem appropriate. Accordingly, during 2018, BioTelemetry conducted a reasonable country of origin inquiry to determine the origin of the 3TG in BioTelemetry’s products.
BioTelemetry believes that industry cooperation is one of the best ways to address issues related to 3TG in an efficient and transparent way. BioTelemetry is engaged and actively cooperates with supply-chain participants and supports the 3TG industry initiatives such as the CFSI driven by the Global e-Sustainability Initiative (“GeSI”) and the Electronic Industry Citizenship Coalition (“EICC”).
In accordance with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the related Supplements for gold, tin, tantalum and tungsten (the “OECD Guidance”), we support the CFSI’s audit of smelters’ and refiners’ due diligence activities. In our internal processes, we use information obtained using CFSI’s Reasonable Country of Origin Inquiry Data for BioTelemetry.
We have identified the following products that may contain Conflict Minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by our consolidated
legal entity, Universal Medical, Inc.: Pacetrak Plus, Pacetrak ENR, Pacetrak Speaks, Heartrak Smart, Heartrak Smart AF, Heartrak 2, and Heartrak ECAT2.
We have identified the following products that may contain Conflict Minerals necessary to the functionality or production of products manufactured, or contracted to manufacture, by our consolidated legal entity, Braemar Manufacturing, LLC: DL800, DL900, DL1200, DTXT, PORT/DOCK, ER8, ER9, ER920W, LOOPER, PER900, Fusion, C5, PSITECIII, CardioKey, EZPUMP, BTP-1000S, BTP-1000M, Heartrak Smart AF, Heartrak 2, Heartrak ECAT 2, TELCARE BGM, and ePatchTM.
3. Due Diligence
BioTelemetry has processes in place for the purpose of exercising due diligence in the supply chain. The design of the due diligence processes conforms substantially to the OECD Guidance as it relates to “downstream” purchasers of products and components. Our position in the supply chain is remote. We do not have a direct relationship with mining companies or with 3TG smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain with 3TG. We rely upon industry efforts to influence smelters and refiners to be audited and certified through CFSI’s Conflict Free Smelter Program.
The due diligence processes have been described below under sub-headings corresponding to the five-step framework of the OECD Guidance.
3.1 Maintain strong management systems
The first step relates to strong management systems. As mentioned above, BioTelemetry has established a program team for reporting on 3TG and compliance with the Rule. This team is responsible for the 3TG implementation work and senior management is regularly informed about matters relating to 3TG. Controls include, but are not limited to, supplier requirements relating to 3TG as described above and are integrated in our template supplier agreements.
With respect to 2018, identification of smelters/refiners in our supply chain was made via the use of due diligence tools created by the CFSI, including the EICC/GeSI Conflict Minerals Reporting Template 4.01 (the “Template”). The Template is a supply chain survey designed to identify the smelters and refiners that process the necessary 3TG contained in our supply chain. The information from our suppliers, in combination with information from the CFSI, helps BioTelemetry to obtain information on the origin of minerals processed. Data obtained was reviewed and analyzed by BioTelemetry.
We have grievance mechanisms, notably a whistleblower tool, managed by an external service provider, for the reporting of alleged violations of laws or the Code of Business Ethics that relate to corruption, questionable accounting, or auditing matters that seriously affect vital interests of the Group or Compliance, in general. Violations reported through the whistleblower tool are handled by BioTelemetry’s Group Compliance Forum, consisting of representatives from BioTelemetry’s Group Function Legal Affairs and Group Function Human Resources. Information regarding incidents is reported to the Compliance and Audit Committees. Reports include measures taken, details of the responsible Group function and the status of any investigation.
3.2 Identify and assess risk in the supply chain
In the second step, risks are identified and assessed. Downstream companies should, with help from their first tier suppliers, identify smelters and refiners in the supply chain.
In BioTelemetry’s 2018 survey, first tier suppliers identified to be in scope were requested by BioTelemetry to provide information on 3TG in their supply chain through completing and submitting the Template. Suppliers were provided with support material, including the generally available instructions and training illustrating the use of the tool that is available on CFSI’s website. To ensure sufficient quality, a high response rate and to minimize risks, the responses received were continuously analyzed and followed up as deemed appropriate. The data obtained was saved, reviewed and analyzed by BioTelemetry. Supplier responses were reviewed against criteria developed to determine which responses required further engagement with our suppliers. These criteria were developed to identify whether the responses from suppliers were incomplete and where further inquiries were necessary. Suppliers were contacted via e-mail or telephone to improve the quality of responses and increase the response rate.
We have had a risk based approach focused on suppliers with incomplete data since they are typically deemed to constitute a higher risk. As part of the risk mitigation efforts, additional efforts were mainly targeted at suppliers that are awarded large parts of our business on an ongoing basis.
3.3 Design and implement a strategy to respond to identified risks
Under the third step companies are encouraged to design and implement a strategy to respond to identified risks. Due diligence within BioTelemetry is an on-going process, both proactive and reactive, where suppliers are continuously evaluated against BioTelemetry’s requirements to ensure that these requirements are systematically incorporated in the suppliers’ processes.
We continuously work to improve our due diligence processes with respect to 3TG, mainly focusing on the quality of data received from suppliers surveyed. This includes communication and collaboration with suppliers for purposes of improving the response rate of surveyed suppliers and improving the reliability and quality of the information provided. As described above, we have a risk based approach when reviewing and following up supplier responses and we generally prioritize suppliers that we frequently purchase from.
3.4 Independent third party audit of smelters’/refiners’ due diligence practices
The fourth step focuses on analysis of smelters’/refiners’ due diligence practices. We support the Conflict Free Smelter Program (“CFSP”) as well as the development and implementation of due diligence practices and tools such as the Template. Due to the structure of our supply chain, there can be many tiers of suppliers between BioTelemetry and the smelters and refiners in the supply chain. We analyze the received data on smelters and refiners and compare such information against the list of facilities that have received a “conflict free” designation from the CFSP. Via the CFSI we also can access information on country of origin and due diligence information on the 3TG sourced by such facilities.
3.5 Report annually on supply chain due diligence
The fifth step encourages reporting on supply chain due diligence. We have a public statement on 3TG on our external website and strive to continuously increase 3TG awareness within BioTelemetry and among suppliers. BioTelemetry’s public statement on the sourcing of 3TG is available on our website: www.gobio.com/investors/corporate-governance/.
In accordance with the Rule, we make our Conflict Minerals Policy available on our website: www.gobio.com/investors/corporate-governance/.
4. Due diligence results - 2018
For the calendar year 2018, our inquiries were made on the supplier level. Inquiries also include responses where suppliers were unable to specify the smelters or refiners used for components supplied to us and certain responses included names of smelters or refiners that we believe may have been misidentified as smelters or refiners that we believe are not operational. Such names have not been listed among identified smelters and refiners.
The response rate among suppliers surveyed in 2018 was 85%. A higher response rate was achieved in the group of suppliers that are awarded a larger part of our business. Among the supplier responses, we identified approximately 286 unique smelters as potential sources of 3TG that were reported to be in the supply chain at some point during the 2018 calendar year. The following table presents, by mineral, the percentages of identified smelters or refiners in our supply chain that have been verified as conflict-free or pledged or committed to CFSI validation.
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| | | | |
| Metal | | Identified smelters verified as CFSP conflict-free, or the smelter pledged or committed to CFSI validation | | Number of identified smelters for each metal |
| Tantalum | | 97.5% | | 41 |
| Tungsten | | 97.6% | | 42 |
| Tin | | 91.1% | | 79 |
| Gold | | 88.8% | | 116 |
We have determined that seeking information about 3TG smelters and refiners in our supply chain represents the most reasonable effort we can make to determine the locations of origin of the 3TG in our supply chain. A list of identified smelters, by mineral, is contained in “Annex I.”
During 2019, we expect to continue to review and evolve our due diligence processes with respect to 3TG. As part of these efforts, we expect to collaborate with suppliers for purposes of further improving the supplier response rate and the reliability and quality of information provided.
Due to the size, breadth and complexity of our products, and the constant evolution of our supply chain, the process of successfully tracing all of the conflict minerals used in our products back to their country of origin will require additional time and resources. We are committed to implementing processes to improve the quantity and quality of responses from our supply chain and to verifying the accuracy and completeness
of the information we receive directly from suppliers or which is otherwise available to us through industry and other initiatives.
Our ability to make determinations about the presence and source of origin of 3TGs in our products depends upon a number of factors including, but not limited to, (i) the respective due diligence efforts of our tier one suppliers and their supply chain, as well as their willingness to disclose such information to us, and (ii) the ability and willingness of our supply chain to adopt the OECD Guidance and other initiatives or guidance that may develop over time with respect to responsible sourcing. The failure to obtain reliable information from any level of our supply chain could have a material impact on our ability to provide meaningful information on the presence and origin of 3TGs in our products’ supply chain with any reasonable degree of certainty. There can be no assurance that our suppliers will continue to cooperate with our diligence inquiries and our requests for certifications or to provide us with the documentation or other evidence that we consider reliable or in a time frame sufficient to allow us to make a reasonable and reliable assessment following appropriate further diligence measures, as may be required.
5. Forward-Looking Statements
Certain of the matters discussed in this report, including in particular our due diligence processes with respect to 3TG, include forward-looking statements. Readers of this document are cautioned that our forward-looking statements are not guarantees of our future actions, which may differ materially from the expectations expressed in the forward-looking statements. We expressly disclaim a duty to provide updates to these forward-looking statements after the date of this filing to reflect events or changes in circumstances or changes in expectations or the occurrence of anticipated events.
The information included on any websites that appear in this report and other materials referenced to is not incorporated by reference in this report.
Annex I
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| Metal | | Smelter or Refiner Name | | Smelter Country |
| Gold | | 8853 S.p.A. | | ITALY |
| Gold | | Advanced Chemical Company | | UNITED STATES OF AMERICA |
| Gold | | Aida Chemical Industries Co., Ltd. | | JAPAN |
| Gold | | Al Etihad Gold Refinery DMCC | | UNITED ARAB EMIRATES |
| Gold | | Allgemeine Gold-und Silberscheideanstalt A.G. | | GERMANY |
| Gold | | Almalyk Mining and Metallurgical Complex (AMMC) | | UZBEKISTAN |
| Gold | | AngloGold Ashanti Corrego do Sitio Mineracao | | BRAZIL |
| Gold | | Argor-Heraeus S.A. | | SWITZERLAND |
| Gold | | Asahi Pretec Corp. | | JAPAN |
| Gold | | Asahi Refining Canada Ltd. | | CANADA |
| Gold | | Asahi Refining USA Inc. | | UNITED STATES OF AMERICA |
| Gold | | Asaka Riken Co., Ltd. | | JAPAN |
| Gold | | AU Traders and Refiners | | SOUTH AFRICA |
| Gold | | Aurubis AG | | GERMANY |
| Gold | | Bangalore Refinery | | INDIA |
| Gold | | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | | PHILIPPINES |
| Gold | | Boliden AB | | SWEDEN |
| Gold | | C. Hafner GmbH + Co. KG | | GERMANY |
| Gold | | CCR Refinery - Glencore Canada Corporation | | CANADA |
| Gold | | Cendres + Metaux S.A. | | SWITZERLAND |
| Gold | | Chimet S.p.A. | | ITALY |
| Gold | | Chugai Mining | | JAPAN |
| Gold | | Daejin Indus Co., Ltd. | | SOUTH KOREA |
| Gold | | Degussa Sonne / Mond Goldhandel GmbH | | GERMANY |
| Gold | | DODUCO Contacts and Refining GmbH | | GERMANY |
| Gold | | Dowa | | JAPAN |
| Gold | | DS PRETECH Co., Ltd. | | REPUBLIC OF KOREA |
| Gold | | DSC (Do Sung Corporation) | | REPUBLIC OF KOREA |
| Gold | | Eco-System Recycling Co., Ltd. | | JAPAN |
| Gold | | Emirates Gold DMCC | | UNITED ARAB EMIRATES |
| Gold | | Geib Refining Corporation | | UNITED STATES OF AMERICA |
| Gold | | Gold Refinery of Zijin Mining Group Co., Ltd. | | CHINA |
| Gold | | Great Wall Precious Metals Co,. LTD. of CBPM | | CHINA |
| Gold | | Gujarat Gold Centre | | INDIA |
| Gold | | HeeSung Metal Ltd. | | REPUBLIC OF KOREA |
| Gold | | Heimerle + Meule GmbH | | GERMANY |
| Gold | | Heraeus Metals Hong Kong Ltd. | | CHINA |
| Gold | | Heraeus Precious Metals GmbH & Co. KG | | GERMANY |
| Gold | | Hunan Chenzhou Mining Industry Co. Ltd. | | CHINA |
| Gold | | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | | CHINA |
| Gold | | Ishifuku Metal Industry Co., Ltd. | | JAPAN |
| Gold | | Istanbul Gold Refinery | | TURKEY |
| Gold | | Italpreziosi | | ITALY |
| Gold | | Japan Mint | | JAPAN |
| Gold | | Jiangxi Copper Co., Ltd. | | CHINA |
| Gold | | JSC Uralelectromed | | RUSSIAN FEDERATION |
| Gold | | JX Nippon Mining & Metals Co., Ltd. | | JAPAN |
| Gold | | Kazakhmys Smelting LLC | | KAZAKHSTAN |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Gold | | Kazzinc | | KAZAKHSTAN |
| Gold | | Kennecott Utah Copper LLC | | UNITED STATES OF AMERICA |
| Gold | | Kojima Chemicals Co., Ltd. | | JAPAN |
| Gold | | Korea Zinc Co., Ltd. | | REPUBLIC OF KOREA |
| Gold | | Kyrgyzaltyn JSC | | KYRGYZSTAN |
| Gold | | Lingbao Gold Company Limited | | CHINA |
| Gold | | L'Orfebre S.A. | | ANDORRA |
| Gold | | LS-NIKKO Copper Inc. | | REPUBLIC OF KOREA |
| Gold | | Marsam Metals | | BRAZIL |
| Gold | | Materion | | UNITED STATES OF AMERICA |
| Gold | | Matsuda Sangyo Co., Ltd. | | JAPAN |
| Gold | | Metalor Technologies (Hong Kong) Ltd. | | CHINA |
| Gold | | Metalor Technologies (Singapore) Pte., Ltd. | | SINGAPORE |
| Gold | | Metalor Technologies (Suzhou) Ltd. | | CHINA |
| Gold | | Metalor Technologies S.A. | | SWITZERLAND |
| Gold | | Metalor USA Refining Corporation | | UNITED STATES OF AMERICA |
| Gold | | Metalurgica Met-Mex Penoles S.A. De C.V. | | MEXICO |
| Gold | | Mitsubishi Materials Corporation | | JAPAN |
| Gold | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN |
| Gold | | MMTC-PAMP India Pvt., Ltd. | | INDIA |
| Gold | | Moscow Special Alloys Processing Plant | | RUSSIAN FEDERATION |
| Gold | | Nadir Metal Rafineri San. Ve Tic. A.S. | | TURKEY |
| Gold | | Navoi Mining and Metallurgical Combinat | | UZBEKISTAN |
| Gold | | Nihon Material Co., Ltd. | | JAPAN |
| Gold | | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | | AUSTRIA |
| Gold | | Ohura Precious Metal Industry Co., Ltd. | | JAPAN |
| Gold | | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | | RUSSIAN FEDERATION |
| Gold | | OJSC Novosibirsk Refinery | | RUSSIAN FEDERATION |
| Gold | | PAMP S.A. | | SWITZERLAND |
| Gold | | Planta Recuperadora de Metales SpA | | CHILE |
| Gold | | Prioksky Plant of Non-Ferrous Metals | | RUSSIAN FEDERATION |
| Gold | | PT Aneka Tambang (Persero) Tbk | | INDONESIA |
| Gold | | PX Precinox S.A. | | SWITZERLAND |
| Gold | | Rand Refinery (Pty) Ltd. | | SOUTH AFRICA |
| Gold | | REMONDIS PMR B.V. | | NETHERLANDS |
| Gold | | Royal Canadian Mint | | CANADA |
| Gold | | SAAMP | | FRANCE |
| Gold | | Safimet S.p.A | | ITALY |
| Gold | | SAFINA A.S. | | CZECH REPUBLIC |
| Gold | | Sai Refining | | INDIA |
| Gold | | Samwon Metals Corp. | | REPUBLIC OF KOREA |
| Gold | | SAXONIA Edelmetalle GmbH | | GERMANY |
| Gold | | SEMPSA Joyeria Plateria S.A. | | SPAIN |
| Gold | | Shandong Humon Smelting Co., Ltd. | | CHINA |
| Gold | | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | | CHINA |
| Gold | | Sichuan Tianze Precious Metals Co., Ltd. | | CHINA |
| Gold | | Singway Technology Co., Ltd. | | TAIWAN |
| Gold | | Smelter Not Listed | | UNITED ARAB EMIRATES |
| Gold | | SOE Shyolkovsky Factory of Secondary Precious Metals | | RUSSIAN FEDERATION |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Gold | | Solar Applied Materials Technology Corp. | | TAIWAN |
| Gold | | Sumitomo Metal Mining Co., Ltd. | | JAPAN |
| Gold | | SungEel HiMetal Co., Ltd. | | REPUBLIC OF KOREA |
| Gold | | T.C.A S.p.A | | ITALY |
| Gold | | Tanaka Kikinzoku Kogyo K.K. | | JAPAN |
| Gold | | The Refinery of Shandong Gold Mining Co., Ltd. | | CHINA |
| Gold | | Tokuriki Honten Co., Ltd. | | JAPAN |
| Gold | | Torecom | | REPUBLIC OF KOREA |
| Gold | | Umicore Brasil Ltda. | | BRAZIL |
| Gold | | Umicore Precious Metals Thailand | | THAILAND |
| Gold | | Umicore S.A. Business Unit Precious Metals Refining | | BELGIUM |
| Gold | | United Precious Metal Refining, Inc. | | UNITED STATES OF AMERICA |
| Gold | | Valcambi S.A. | | SWITZERLAND |
| Gold | | Western Australian Mint (T/a The Perth Mint) | | AUSTRALIA |
| Gold | | WIELAND Edelmetalle GmbH | | GERMANY |
| Gold | | Yamakin Co., Ltd. | | JAPAN |
| Gold | | Yokohama Metal Co., Ltd. | | JAPAN |
| Gold | | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | | CHINA |
| Gold | | Zijin Mining Group Co., Ltd. Gold Refinery | | CHINA |
| Tantalum | | Asaka Riken Co., Ltd. | | JAPAN |
| Tantalum | | Changsha South Tantalum Niobium Co., Ltd. | | CHINA |
| Tantalum | | D Block Metals, LLC | | UNITED STATES OF AMERICA |
| Tantalum | | Exotech Inc. | | UNITED STATES OF AMERICA |
| Tantalum | | F&X Electro-Materials Ltd. | | CHINA |
| Tantalum | | FIR Metals & Resource Ltd. | | CHINA |
| Tantalum | | Global Advanced Metals Aizu | | JAPAN |
| Tantalum | | Global Advanced Metals Boyertown | | UNITED STATES OF AMERICA |
| Tantalum | | Guangdong Rising Rare Metals-EO Materials Ltd. | | CHINA |
| Tantalum | | Guangdong Zhiyuan New Material Co., Ltd. | | CHINA |
| Tantalum | | H.C. Starck Co., Ltd. | | THAILAND |
| Tantalum | | H.C. Starck Hermsdorf GmbH | | GERMANY |
| Tantalum | | H.C. Starck Inc. | | UNITED STATES OF AMERICA |
| Tantalum | | H.C. Starck Ltd. | | JAPAN |
| Tantalum | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY |
| Tantalum | | H.C. Starck Tantalum and Niobium GmbH | | GERMANY |
| Tantalum | | Hengyang King Xing Lifeng New Materials Co., Ltd. | | CHINA |
| Tantalum | | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | | CHINA |
| Tantalum | | Jiangxi Tuohong New Raw Material | | CHINA |
| Tantalum | | Jiujiang Janny New Material Co., Ltd. | | CHINA |
| Tantalum | | JiuJiang JinXin Nonferrous Metals Co., Ltd. | | CHINA |
| Tantalum | | Jiujiang Tanbre Co., Ltd. | | CHINA |
| Tantalum | | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | | CHINA |
| Tantalum | | KEMET Blue Metals | | MEXICO |
| Tantalum | | KEMET Blue Powder | | UNITED STATES OF AMERICA |
| Tantalum | | LSM Brasil S.A. | | BRAZIL |
| Tantalum | | Metallurgical Products India Pvt., Ltd. | | INDIA |
| Tantalum | | Mineracao Taboca S.A. | | BRAZIL |
| Tantalum | | Mitsui Mining and Smelting Co., Ltd. | | JAPAN |
| Tantalum | | Ningxia Orient Tantalum Industry Co., Ltd. | | CHINA |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Tantalum | | NPM Silmet AS | | ESTONIA |
| Tantalum | | Power Resources Ltd. | | NORTH MACEDONIA |
| Tantalum | | QuantumClean | | UNITED STATES OF AMERICA |
| Tantalum | | Resind Industria e Comercio Ltda. | | BRAZIL |
| Tantalum | | Solikamsk Magnesium Works OAO | | RUSSIAN FEDERATION |
| Tantalum | | Taki Chemical Co., Ltd. | | JAPAN |
| Tantalum | | Telex Metals | | UNITED STATES OF AMERICA |
| Tantalum | | Ulba Metallurgical Plant JSC | | KAZAKHSTAN |
| Tantalum | | XinXing HaoRong Electronic Material Co., Ltd. | | CHINA |
| Tantalum | | Yanling Jincheng Tantalum & Niobium Co., Ltd. | | CHINA |
| Tantalum | | Zhuzhou Cemented Carbide Group Co., Ltd. | | CHINA |
| Tin | | Alpha | | UNITED STATES OF AMERICA |
| Tin | | An Thai Minerals Co., Ltd. | | VIET NAM |
| Tin | | An Vinh Joint Stock Mineral Processing Company | | VIET NAM |
| Tin | | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | | CHINA |
| Tin | | Chifeng Dajingzi Tin Industry Co., Ltd. | | CHINA |
| Tin | | China Tin Group Co., Ltd. | | CHINA |
| Tin | | CV Ayi Jaya | | INDONESIA |
| Tin | | CV Dua Sekawan | | INDONESIA |
| Tin | | CV Gita Pesona | | INDONESIA |
| Tin | | CV United Smelting | | INDONESIA |
| Tin | | CV Venus Inti Perkasa | | INDONESIA |
| Tin | | Dowa | | JAPAN |
| Tin | | EM Vinto | | BOLIVIA |
| Tin | | Fenix Metals | | POLAND |
| Tin | | Gejiu Fengming Metallurgy Chemical Plant | | CHINA |
| Tin | | Gejiu Kai Meng Industry and Trade LLC | | CHINA |
| Tin | | Gejiu Non-Ferrous Metal Processing Co., Ltd. | | CHINA |
| Tin | | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | | CHINA |
| Tin | | Gejiu Zili Mining And Metallurgy Co., Ltd. | | CHINA |
| Tin | | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | | CHINA |
| Tin | | Guanyang Guida Nonferrous Metal Smelting Plant | | CHINA |
| Tin | | HuiChang Hill Tin Industry Co., Ltd. | | CHINA |
| Tin | | Huichang Jinshunda Tin Co., Ltd. | | CHINA |
| Tin | | Jiangxi New Nanshan Technology Ltd. | | CHINA |
| Tin | | Magnu's Minerais Metais e Ligas Ltda. | | BRAZIL |
| Tin | | Malaysia Smelting Corporation (MSC) | | MALAYSIA |
| Tin | | Melt Metais e Ligas S.A. | | BRAZIL |
| Tin | | Metallic Resources, Inc. | | UNITED STATES OF AMERICA |
| Tin | | Metallo Belgium N.V. | | BELGIUM |
| Tin | | Metallo Spain S.L.U. | | SPAIN |
| Tin | | Mineracao Taboca S.A. | | BRAZIL |
| Tin | | Minsur | | PERU |
| Tin | | Mitsubishi Materials Corporation | | JAPAN |
| Tin | | Modeltech Sdn Bhd | | MALAYSIA |
| Tin | | O.M. Manufacturing (Thailand) Co., Ltd. | | THAILAND |
| Tin | | O.M. Manufacturing Philippines, Inc. | | PHILIPPINES |
| Tin | | Operaciones Metalurgicas S.A. | | BOLIVIA |
| Tin | | PT Aries Kencana Sejahtera | | INDONESIA |
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| Metal | | Smelter or Refiner Name | | Smelter Country |
| Tin | | PT Artha Cipta Langgeng | | INDONESIA |
| Tin | | PT ATD Makmur Mandiri Jaya | | INDONESIA |
| Tin | | PT Babel Inti Perkasa | | INDONESIA |
| Tin | | PT Babel Surya Alam Lestari | | INDONESIA |
| Tin | | PT Bangka Prima Tin | | INDONESIA |
| Tin | | PT Bangka Timah Utama Sejahtera | | INDONESIA |
| Tin | | PT Bangka Tin Industry | | INDONESIA |
| Tin | | PT Belitung Industri Sejahtera | | INDONESIA |
| Tin | | PT Bukit Timah | | INDONESIA |
| Tin | | PT DS Jaya Abadi | | INDONESIA |
| Tin | | PT Inti Stania Prima | | INDONESIA |
| Tin | | PT Kijang Jaya Mandiri | | INDONESIA |
| Tin | | PT Menara Cipta Mulia | | INDONESIA |
| Tin | | PT Mitra Stania Prima | | INDONESIA |
| Tin | | PT O.M. Indonesia | | INDONESIA |
| Tin | | PT Panca Mega Persada | | INDONESIA |
| Tin | | PT Premium Tin Indonesia | | INDONESIA |
| Tin | | PT Prima Timah Utama | | INDONESIA |
| Tin | | PT Rajawali Rimba Perkasa | | INDONESIA |
| Tin | | PT Rajehan Ariq | | INDONESIA |
| Tin | | PT Refined Bangka Tin | | INDONESIA |
| Tin | | PT Sariwiguna Binasentosa | | INDONESIA |
| Tin | | PT Stanindo Inti Perkasa | | INDONESIA |
| Tin | | PT Sukses Inti Makmur | | INDONESIA |
| Tin | | PT Sumber Jaya Indah | | INDONESIA |
| Tin | | PT Timah Tbk Kundur | | INDONESIA |
| Tin | | PT Timah Tbk Mentok | | INDONESIA |
| Tin | | PT Tinindo Inter Nusa | | INDONESIA |
| Tin | | PT Tirus Putra Mandiri | | INDONESIA |
| Tin | | PT Tommy Utama | | INDONESIA |
| Tin | | Resind Industria e Comercio Ltda. | | BRAZIL |
| Tin | | Rui Da Hung | | TAIWAN |
| Tin | | Smelter not listed | | VIETNAM |
| Tin | | Soft Metais Ltda. | | BRAZIL |
| Tin | | Thaisarco | | THAILAND |
| Tin | | Tin Technology & Refining | | UNITED STATES OF AMERICA |
| Tin | | VQB Mineral and Trading Group# | | VIETNAM |
| Tin | | White Solder Metalurgia e Mineracao Ltda. | | BRAZIL |
| Tin | | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | | CHINA |
| Tin | | Yunnan Tin Company Limited | | CHINA |
| Tin | | Yunnan Tin Group (Holding) Company Limited | | CHINA |
| Tungsten | | A.L.M.T. Corp. | | JAPAN |
| Tungsten | | ACL Metais Eireli | | BRAZIL |
| Tungsten | | Asia Tungsten Products Vietnam Ltd. | | VIETNAM |
| Tungsten | | Chenzhou Diamond Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Chongyi Zhangyuan Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Fujian Jinxin Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Haichuang Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Huaxing Tungsten Products Co., Ltd. | | CHINA |
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| | | | |
| Metal | | Smelter or Refiner Name | | Smelter Country |
| Tungsten | | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | | CHINA |
| Tungsten | | Ganzhou Seadragon W & Mo Co., Ltd. | | CHINA |
| Tungsten | | Global Tungsten & Powders Corp. | | UNITED STATES OF AMERICA |
| Tungsten | | Guangdong Xianglu Tungsten Co., Ltd. | | CHINA |
| Tungsten | | H.C. Starck Smelting GmbH & Co. KG | | GERMANY |
| Tungsten | | H.C. Starck Tungsten GmbH | | GERMANY |
| Tungsten | | Hunan Chenzhou Mining Co., Ltd. | | CHINA |
| Tungsten | | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | | CHINA |
| Tungsten | | Hunan Chuangda Vanadium Tungsten Co., Ltd. Yangling | | CHINA |
| Tungsten | | Hunan Chunchang Nonferrous Metals Co., Ltd. | | CHINA |
| Tungsten | | Hydrometallurg, JSC | | RUSSIAN FEDERATION |
| Tungsten | | Japan New Metals Co., Ltd. | | JAPAN |
| Tungsten | | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Gan Bei Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | | CHINA |
| Tungsten | | Jiangxi Yaosheng Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Kennametal Fallon | | UNITED STATES OF AMERICA |
| Tungsten | | Kennametal Huntsville | | UNITED STATES OF AMERICA |
| Tungsten | | KGETS Co., Ltd. | | REPUBLIC OF KOREA |
| Tungsten | | Malipo Haiyu Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Masan Tungsten Chemical LLC (MTC) | | VIETNAM |
| Tungsten | | Moliren Ltd. | | RUSSIAN FEDERATION |
| Tungsten | | Niagara Refining LLC | | UNITED STATES OF AMERICA |
| Tungsten | | Philippine Chuangxin Industrial Co., Inc. | | PHILIPPINES |
| Tungsten | | South-East Nonferrous Metal Company Limited of Hengyang City | | CHINA |
| Tungsten | | Tejing (Vietnam) Tungsten Co., Ltd. | | VIETNAM |
| Tungsten | | Unecha Refractory metals plant | | RUSSIAN FEDERATION |
| Tungsten | | Wolfram Bergbau und Hutten AG | | AUSTRIA |
| Tungsten | | Woltech Korea Co., Ltd. | | REPUBLIC OF KOREA |
| Tungsten | | Xiamen Tungsten (H.C.) Co., Ltd. | | CHINA |
| Tungsten | | Xiamen Tungsten Co., Ltd. | | CHINA |
| Tungsten | | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | | CHINA |
| Tungsten | | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | | CHINA |
